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1 <br /> soils can be handled as non-hazardous, otherwise, Class I <br /> transporters and disposal facilities would be required. Specific <br /> characteristics in question are toxicity and concentrations of <br /> "persistent and bioaccumulative toxic substances" (metals ) . <br /> Other Article 11 characteristics (ignitability, reactivity, and <br /> corrosivity) have been deemed not applicable to the waste in <br /> question. <br /> BJJ Company is in a difficult position regarding timing for <br /> removal of the excavated soils. A substantial road construction <br /> project involving on-site and off-site properties requires <br /> immediate removal of the excavated soils. Due to the large <br /> volume of soils excavated at this site, disposal at even a Class <br /> II facility would be extremely cost prohibitive in addition to <br /> being an inefficient use of landfill space. Therefore, WaterWork <br /> proposes to transport the excavated soils off-site to BJJ Company <br /> owned property at 2431 East Mariposa Road in Stockton and place <br /> it on 6 mil plastic sheeting for subsequent treatment and <br /> disposal. <br /> Although we do not concur with the interpretation and <br /> implementation of Title 22 criteria to diesel contaminated soils, <br /> additional samples have been collected and are currently being <br /> analyzed for toxicity by 96-hour bioassay and for total soluble <br /> concentrations of Title 22 metals. Since the County requires <br /> . self-certification of the soils as nonhazardous prior to handling <br /> by non-Class I facilities, we will await analytical results prior <br /> to transporting the soils. If the laboratory analyses indicate <br /> that the soils are not considered hazardous pursuant to Title 22, <br /> we intend to began transporting soils immediately. Completion of <br /> laboratory analyses are anticipated no later than October 9, <br /> 1990. Treatment and ultimate disposal of the excavated soils <br /> will be addressed in a proposed workplan as will further <br /> assessment of residual soil contamination and potential <br /> water c enation. This report will be submitted by <br /> November 1, 1990. <br /> l <br /> 2 A U it is not our intent to place blame, it should be taken <br /> b into consideration that the "emergency" nature of this situation <br /> is primarily due to the lengthy delay between submittal of the <br /> PAR ( February ) and authorization to proceed ( September ) . <br /> y� Additionally, I believe that the County' s apparent policy that <br /> d) all wastes be characterized pursuant to Title 22 or be handled as <br /> q41- a hazardous waste is setting an unreasonable and dangerous <br /> precedent. <br /> ,` """a�`'" <br />